Prepare a memo to the IRS in response to the NOPA to initiate the appeal (see attachment). The response will discuss the issue associated with the proposed adjustment, explain why your client disagrees, and include relevant legal research to defend your client’s case. Be sure to read the NOPA in its entirety in order to formulate a clear and thorough response. The following critical elements must be addressed in 3 pages to the client. Prepare a memo to the IRS on behalf of the client in response to the NOPA. The memo must include the three sections: I.Issues: Identify each item that the IRS challenged your client on in the NOPA, and clearly state how the client intends to respond to the proposed adjustment. II.Stance: Declare your client’s stance on the items identified above by briefly explaining which facts or legal arguments in the NOPA you consider to be in error and why. III.Support: Explain why your client’s appeal should be granted, using relevant legal research to support their case. You may include Internal Revenue Code, regulations, reference to past revenue rulings, and/or revenue procedures in your defense.